To execute comprehensive AML/KYC due diligence activities during onboarding and periodic review of clients/investors. The role requires rigorous attention to every stage of the due diligence lifecycle, from data collection through risk evaluation, verification, and record maintenance.

1. Collection and Verification of Documentation  Initial Documentation Request: Communicate directly the dedicate client facing function to request all required AML/KYC documents, specifying the exact type and format acceptable (e.g. certified true copy, translation requirements, apostille as needed).  Document Review: Examine and validate identification documents (passports, national IDs, corporate registration, beneficial ownership structures, proof of address, source of wealth/source of funds evidence) for completeness, authenticity, and alignment with declared information.  Beneficial Ownership Analysis: Identify, document, and verify all ultimate beneficial owners (UBOs), controllers, and significant persons associated with the client/investor, in line with the latest regulatory thresholds and definitions.  Tax and Regulatory Classification: Collect and record information for FATCA, CRS, ensuring proper classification (US person, reportable account, direct investment versus intermediary etc.) and obtain self-certifications where required.

2. In-depth AML Risk Assessment Application of Risk Scoring Models: Assess AML risk based on the client’s jurisdiction, entity type, ownership structure, product type, distribution channel, and the nature of expected transactions. Risk Factors Evaluation: Thoroughly consider standard and enhanced risk factors such as:  Politically Exposed Person (PEP) involvement  Business/sector risk (e.g., cash-intensive businesses, trust/charity structures)  Geographical (country of residence/incorporation) risk ratings – high, standard, or low, referencing the most recent risk maps and regulatory guidance  Complex ownership/asset structures or use of intermediaries  Unusual or opaque sources of wealth or funding Risk Rating Assignment: Assign an overall risk score (e.g., Low/Medium/High) in accordance with defined guidelines. Clearly document the justification for each risk rating step.

3. Name Screening and Negative Media Checks

KYC Screening: Conduct KYC name screening for all relevant parties (client/investor, UBOs, directors, signatories) against:  Sanctions lists (OFAC, EU, UN, HMT, etc.)  PEP databases  Adverse media/news (e.g. World-Check, Dow Jones)

Handling:  Log all screening hits and determine genuine matches versus false positives using robust procedures.  Investigate potential matches, assess risk implications, and escalate genuine hits to Senior Analysts or Team Leaders per escalation matrix.  Document all screening findings and investigations, ensuring clarity and auditability. For more guidance, please refer to the section Screening Investigation and Documentation at the end of this document.

4. Due Diligence Level Application & Enhanced Due Diligence Activities Determine Due Diligence Level: Apply the correct level of due diligence (Standard or Enhanced) as determined by the risk assessment. For Standard Due Diligence: Satisfy baseline identification and verification steps and review for basic red flags. For Enhanced Due Diligence (EDD): Conduct additional verification steps which may include:  Seeking independent or corroborative evidence of source of wealth/funds  Gathering additional documentation for high-risk countries or complex structures  Conducting web-screening for reputational risk  Liaising with compliance for approval prior to onboarding/investment approval Ongoing Monitoring: Participate in periodic reviews, event-driven reviews (triggers such as change in ownership, negative news, new PEP status), and transaction monitoring reviews as instructed.

5. Record Keeping, System Updates and Reporting Data Entry: Ensure accurate and timely updates to due diligence data in KYC and investor registry systems; maintain detailed and logically organised electronic files and audit trails. Reporting: Prepare internal checklists, due diligence summaries with explanatory narrative on the due diligence performed (e.g.: risk driver, red flag), and escalate files requiring review in a clear, fully documented manner.

6. Communication and Support Investor and Counterparty Queries: Efficiently handle inbound and outbound communications (phone, email, conference calls) related to document requests, clarification of AML requirements, regulatory queries, and case status updates. Collaboration: Work closely with Senior Analysts, Team Leaders, Compliance, and other internal stakeholders to resolve open points and ensure seamless onboarding or review.

7. Compliance and Continuous Learning Procedural Adherence: Apply customer's AML and investor onboarding procedures meticulously, escalating any uncertainty or potential non-compliance immediately. Procedure Updates: Stay aware of changes in AML/KYC internal policies; complete required training and compliance e-learning.

8. Know your distribution (KYD) – where applicable  Collect Required Documentation: Obtain and verify the signed Distribution/Platform/Placing Agent Agreement for every new or existing distributor/platform relationship, ensuring it meets client requirements.  Industry Standard Questionnaires: Request completed Industry Standard Due Diligence Questionnaires (DDQ) and Wolfsberg Questionnaires from the intermediary. Verify that all questions are answered; any blanks or “not applicable” responses must be chased—do not consider the documentation complete until all required fields are filled.  Preliminary Review: Check received documents for authenticity, completeness, and adherence to expected formats. Flag missing, unclear, or unsigned documentation and escalate promptly.  Basic Information Gathering: Document the nature of the relationship, including the profile and type of end clients targeted by the distributor (e.g., HNWI, retail, institutional) as stated in the DDQ or supporting material.  File Maintenance: Ensure all KYD documents and correspondence are clearly filed, up-to-date, and accessible for review.

 Bachelor’s degree in business, finance, law or similar preferred.  0–2 years’ experience in AML/KYC or related field; relevant internships accepted.  Essential attributes: Rigorous attention to detail, methodical approach, high integrity, and willingness to escalate issues.  Ability to communicate clearly in English; additional languages are an asset (APAC/European).  Proficiency with office productivity tools; prior exposure to KYC/AML systems advantageous.  Strong interpersonal skills and team focus

The role holder shall ensure that all their responsibilities are performed to the highest levels of integrity, quality and transparency and in a manner most likely to promote the success of the client, taking into account the interests of key stakeholders including clients, employees, regulators, suppliers and society as a whole. In discharging their responsibilities, the individual shall establish appropriate oversight and control structures for all areas under their control where needed. Reporting Obligations In discharging their responsibilities, the role holder shall  Ensure that AML Services - Team Leader is made aware of any issues, or red flag which the Analyst deems material  Provide to the AML Services - Team Leader an annual assessment of their own performance against objectives agreed with them

This role is within an entity/or entities which are covered by the UK’s Senior Manager and Certification Regime. As such, the role holder is required to comply with the following Individual Conduct Rules: Rule 1: You must act with integrity Rule 2: You must act with due skill, care and diligence Rule 3: You must be open and cooperative with the FCA, PRA and any other regulators Rule 4: You must pay due regard to the interests of customers and treat them fairly Rule 5: You must observe proper standards of market conduct

Screening Investigation and Documentation

Thorough Recordkeeping: Ensure all screening activities and their outcomes—whether relating to clients, UBOs, directors, or connected parties—are fully substantiated. For every screening cycle and every retain documentation and rationale for all outcomes, including for false positives.

Investigation of Screening Hits: Each (hit) generated (e.g. adverse media, PEP, sanctions, law/regulatory enforcement) must undergo a full investigation to determine its relevance:  Assess whether the hit is a true match to the business relationship by reviewing identifiers (e.g. name, DOB, country, occupation).  Use investigative tools and all available data to discount or confirm a match. Types of Match and Timeframes: After investigation, each must be resolved and classified within the following timeframes:  Sanction s: Review and escalate within one business day.  PEP/RCAs & Adverse Media/Other s: Review and escalate where required within three business days.

False Match: Clearly document reason for discounting; at least two separate factors/reasonings must be recorded.

Positive Match: Document rationale, include next steps or mitigation, and escalation

Maker-Checker Control:

All s handled by an initial reviewer (“maker”) must always be reviewed by a separate checker prior to resolution: The checker independently validates the findings and the rationale, ensuring all procedures are followed and that the documentation is clear and complete. Where doubt or complexity remains at either stage, escalation to the next level of management is mandatory—no cases with unresolved uncertainty may be closed by the original handler.

Documentation Standards:

For every , the investigation narrative must:  Clearly state the findings (e.g. confirmed match or no match), referencing objective identifiers.  Articulate the investigative steps, evidence reviewed, and the two or more key reasons supporting the outcome especially for false positives).  For positive matches, provide a rationale for continuing or ceasing the business relationship and detail any additional mitigating steps.  Apply and record the risk rating of the relationship where s have been reported on the relationship and related parties.  If information is insufficient to make a final determination, clearly state what is missing, record attempts to obtain it, and update the file once additional data is received.  Ensure that the rationale and conclusion of every investigation is clear, concise, and able to withstand retrospective review by internal/external auditors or regulators.